EPA 910/9-89-006
Puget Sound Estuary Program
EVERETT HARBOR ACTION PROGRAM:
1989 ACTION PLAN
March 1989

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PTI Environmental Services
3625 - 132nd Avenue SE
Suite 301
Bellevue, Washington  98006
EVERETT HARBOR ACTION PROGRAM:
1989 ACTION PLAN
For

U.S. Environmental Protection Agency
Region 10 - Office of Puget Sound
Seattle, Washington  98101

EPA 910/9/-89-006
EPA Contract No. 68D80085
PTI Contract No. C744-04
March 1989

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                                   CONTENTS


                                                                              Page

LIST OF FIGURES                                                              iii

LIST OF TABLES                                                               iv

GLOSSARY AND LIST OF ABBREVIATIONS                                       v

ACKNOWLEDGMENTS                                                         vii

EXECUTIVE SUMMARY                                                        ix

INTRODUCTION                                                               1

     OVERVIEW OF EVERETT HARBOR AND ITS TOXIC CONTAMINATION
     PROBLEMS                                                               1

     EVERETT HARBOR ACTION PROGRAM                                     4

          Implementation of Action Plans                                          4
          Past Accomplishments                                                  6

     TECHNICAL APPROACH                                                   7

          Identification and Ranking of Problem  Areas                               7
          Identification of Potential Contaminant Sources                             9

1989 ACTION PLAN FOR EVERETT HARBOR                                     14

     COMPREHENSIVE PROGRAMS AND PLANS                                  14

          U.S. Environmental Protection Agency   Superfund                          14
          Proposed U.S. Navy Homeport for a Carrier Battle Group                    14
          Washington Department of Ecology                                       15
          Snohomish Conservation District                                          16
          Snohomish Health District                                               17
          City of Everett                                                        17
          Puget  Sound Water Quality Authority                                      18
          U.S. Army Corps of Engineers -  Puget Sound Dredged
            Disposal Analysis                                                     18
          Port of Everett                                                        19
          Paine  Field Cleanup Committee                                          19

     SITE-SPECIFIC ACTION PLAN                                              19

REFERENCES                                                                  22

APPENDIX A: SOURCE EVALUATION SUMMARY

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                                       FIGURES


Number                                                                              Page

   1      Everett Harbor and lower Snohomish River project area                          2

   2      Elements of the Everett Harbor Action Program                                 5

   3      Environmental indicators used  to define problem areas of sediment
          contamination and biological effects                                            8

   4      Problem areas and problem stations in the  Everett Harbor project area           10

   5      Locations of potential sources of contamination in the Everett Harbor
          project area                                                                  12

   6      Locations of drain sampling stations, industrial discharge outfalls,
          CSOs, and storm drains in the  East Waterway study area                         13
                                            111

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                                       TABLES






Number                                                                           Page




   1     Site-specific action plan for Everett Harbor priority problem areas              20
                                          IV

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                     GLOSSARY AND LIST OF ABBREVIATIONS
AGENCY AND

CAC

COE

Ecology

EHAT

EPA

IAWG

NPDES

PSDDA

PSEP



PSWQA

RCRA

Superfund
PROGRAM NAMES

          Citizens Advisory Committee

          U.S. Army Corps of Engineers

          Washington Department of Ecology

          Everett Harbor Action Team

          U.S. Environmental Protection Agency

          Interagency Work Group

          National Pollutant Discharge Elimination System (EPA/Ecology)

          Puget Sound Dredged Disposal Analysis Program

          Puget Sound Estuary  Program  (EPA/Ecology/PSWQA), including
          urban  bay  action  programs such as  the Everett  Harbor  Action
          Program

          Puget Sound Water  Quality Authority

          Resource Conservation and Recovery Act

          EPA and Ecology programs under the Comprehensive Environmental
          Response, Compensation and Liability Act to clean up hazardous
          waste sites or other areas of  toxic contamination
CHEMICAL NAMES

HPAH

LPAH

PAH

PCBs
          High molecular weight polycyclic aromatic hydrocarbons

          Low molecular weight polycyclic aromatic hydrocarbons

          Polycyclic aromatic hydrocarbons

          Polychlorinated biphenyls
POLLUTANT SOURCE NAMES
cso
          Combined sewer overflow.   A discharge of  raw sewage  diluted
          with stormwater,  which occurs whenever  the hydraulic capacity
          of a combined sewer line is exceeded.

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OTHER TERMS

AET
Amphipod



Benthic

Bioaccumulation



Bioassay



Community


Diversity



Infauna

Invertebrates

Lesion


Loading


Nonpoint Source


Sediment


Toxic Contamination
Apparent effects threshold.  Chemical concentrations  in sediments
above  which  a  particular  adverse  biological  effect  is  expected
to  be  statistically  significant  (P<0.05)  relative  to  appropriate
reference conditions.

A  small  organism  that  superficially  resembles  a  shrimp  and
lives  on  the  sea  bottom.    Amphipods  are  used in  laboratory
bioassays  to test the toxicity of sediments.

Pertaining to the bottom of a body of water

The accumulation  of  a  substance in  tissues  of an organism.
Bioaccumulation  of  toxic  substances  may  lead  to  disease  or
other health-problems.

A  laboratory  test  used  to  evaluate  the  toxicity  of a  material
(commonly  sediments  or wastewater) by  measuring  behavioral or
physiological responses (including death) of organisms.

A  group  of  interacting  species  populations  found within   a
defined area.

The  number  of species  in  a  community,  or  a   mathematical
index  of  the  variety  of  species that  also  accounts  for  the
relative abundance of each species.

Animals living within the bottom sediments.

Animals without backbones.

An  abnormal structural  change  in the  body due  to injury or
disease (e.g., a liver tumor in fish).

Quantity  of a  substance  that  enters  a body of  water  during  a
specified time interval (e.g., pounds per year).

A  nonspecific  source  of  pollutants,  often  from  a large  area
(e.g., stormwater drainage).

Material  that settles to the bottom of a body of water  or that
collects on the bottom of pipes such as  sewers and storm drains.

Presence  of  toxic  substances,  often  caused  by   releases  of
metals or synthetic organic chemicals to the environment.
                                            VI

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                                ACKNOWLEDGMENTS
     This document was  prepared by  PTI Environmental Services under  the  direction  of
Dr. Robert  A. Pastorok for  the  U.S.  Environmental Protection  Agency  (EPA)  in  partial
fulfillment of  Contract  No. 68D80085.    This  project  was funded through  the National
Estuary Program  under the authority of  the  Clean Water Act  as  amended.   Funding was
approved  by the EPA  Office of Marine and  Estuarine Protection.   An  earlier draft  of
this report was prepared  under contract  to Tetra Tech, Inc.  for  EPA.    Dr.  Jean  Jacoby
was  the  technical  monitor  for  Tetra  Tech,  Inc.    Dr.  Lawrence McCrone, Ms.  Clare
Ryan,  Ms.  Martha  Burke,  and  Dr.  John  Armstrong  served  as  technical monitors  for
EPA Region 10 throughout various  phases of the project.

     The primary authors of  this report are Mr.  Pieter Booth  and Dr.  Robert Pastorok
of  PTI  Environmental  Services.   Dr. Thomas  Ginn of PTI provided  technical  review
comments.

     The Everett Harbor Action Program has  benefited  from  the  participation  of  an
Interagency  Work Group  and  a  Citizens  Advisory  Committee.    Duties  of  the  Everett
Harbor Interagency  Work  Group  and Citizens Advisory  Committee  members  included the
following:   1) reviewing  program  documents,  agency  policies, and proposed  actions;  2)
providing  data  reports  and  other technical   information  to  the  U.S. Environmental
Protection  Agency;  and  3)  disseminating  information  to  interest  groups  or constitu-
encies.   The  past and  continuing efforts of the Everett  Harbor  Interagency  Work  Group
and  Citizens  Advisory  Committee members  are  greatly appreciated.   Special  thanks are
due  to  Ms.  Joan  Thomas,  Mr.  David  Murdock,  Mr.  David Nunnallee,  and  Mr.  John
Williams for chairing the Everett Harbor Interagency Work  Group and to Mr. Gary  Wold
for chairing  the  Everett  Harbor  Citizens Advisory  Committee.    Members of the Everett
Harbor Interagency Work Group and Citizens Advisory Committee are listed below.
Everett Harbor Interagency Work Group

             Name                                Affiliation

     Mr. Chuck Dunn             U.S. Fish and Wildlife Service
     Ms. Katherine Fletcher        Puget Sound Water Quality Authority
     Dr. Jack Gakstatter           U.S. Environmental Protection Agency
     Mr. Dennis Gregoire          Port of Everett
     Mr. Nathan Jacobson          Snohomish Conservation District
     Dr. David Jamison            Washington Department of Natural Resources
     Mr. Edward Long             National Oceanic and Atmospheric Administration
     Mr. Edward Lukjanowicz      U.S. Navy Homeporting  Office
     Mr. David Peterson           Snohomish Health District
     Dr. Lawrence McCrone        Washington Department of Ecology
     Mr. William Moore            Mayor of Everett
     Mr. David Murdock           Washington Department of Ecology
     Mr. Thomas Niemann         Snohomish County Planning Department
     Mr. David Nunnallee          Washington Department of Ecology
     Mr. Clair Olivers             City of Everett
     Ms. Sandra O'Neil             Washington Department of Fisheries
                                          vn

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            Name
               Affiliation
Everett Harbor Interagency Work Group (continued)
     Mr. David Peterson
     Ms. Clare Ryan
     Mr. Carl Sagerser
     Mr. David Somers
     Ms. Joan Thomas
     Mr. Ron Thomas
     Mr. James Thornton
     Mr. John Underwood
     Mr. Frank Urabeck
     Mr. John Williams
     Mr. Harry Winder
     Mr. William Yake
     Lt. Cmdr. Greg Yaroch
Snohomish Health District
Washington Department of Ecology
Washington Department of Social and Health Services
Tulalip Tribes
Washington Department of Ecology
City of Everett
Washington Department of Ecology
U.S. Environmental Protection Agency
U.S. Army Corps of Engineers, Seattle District
Washington Department of Ecology
Port of Everett
Washington Department of Ecology
Port Marine Safety Office
Everett Harbor Citizens Advisory Committee

             Name
     Mr. Dennis Atkinson
     Mr. Timothy Bechtel
     Mr. Ronald Brown
     Mr. William Brust
     Mr. T.M. Burns
     Mr. Carl Cady
     Mr. Michael Deller
     Mr. Alan Friedman
     Ms. Anne Grubb
     Ms. Lorena Havens
     Mr. James Heil
     Mr. Mark Houser
     Mr. Peter Hurley
     Mr. Henry Krai
     Mr. Donald Kusler
     Ms. Sally Van Niel
     Mr. Gary Wold
            Affiliation
Everett Chamber of Commerce
Scott Paper Company
Friends of the Snohomish River
Citizens for Everett's Future
Everett Chamber of Commerce
Weyerhaeuser Company
Snohomish County Economic Development Council
Sierra Club
Pilchuck  Audubon Society
Friends of Snohomish Delta
Puget Sound Alliance
Port Gardner Information League
Evergreen Coalition
Everett Mountaineers
Pilchuck  Audubon Toxics
Washington Environmental Council
Trout Unlimited
                                         Vlll

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                                EXECUTIVE SUMMARY
     Previous  studies of  Everett  Harbor  and  the  lower  Snohomish  River have revealed
extensive  contamination  of sediments  by  toxic  metals such  as copper,  lead,  zinc,  and
arsenic, as  well as  organic  compounds  such  as  petroleum  products  and  polychlorinated
biphenyls.   Some  of these substances  may pose hazards  to the aquatic ecosystem.   For
example,  toxic  contamination  may  decrease   the  abundance  and  diversity   of bottom-
dwelling (benthic)  invertebrate  communities,  increase  the  prevalence of  tissue  disorders
such as liver  tumors in fish,  and  result  in the accumulation of chemicals  in  tissues of
fish and shellfish.

     The   U.S.  Environmental  Protection  Agency  and   the  Washington  Department  of
Ecology  (Ecology),  working  with the  City of Everett  and others,  developed  the  Urban
Bay  Action  Program to reduce toxic  contamination  in urban  bays  including the Everett
Harbor system.    The  Everett  Harbor Action Program  1)  identifies  existing  areas  of
toxic  contamination,  2) identifies known  and  potential sources  of toxic contaminants, 3)
establishes  schedules  for corrective  actions  to  eliminate existing problems and  investigate
potential  problems,  and  4)  identifies  appropriate  agencies for  implementing  corrective
actions.  Corrective actions may include both source controls and sediment  remedial  actions
(i.e., cleanup),  such  as capping  or  removal of contaminated  sediments.  Source controls
may include  permit  revisions  (or  permitting  of  unpermitted  discharges) that  require  a
reduction   of  contaminant concentrations   or  volume  of  discharges,  and  application  of
best management practices to reduce the contamination of surface runoff.

     Priority problem  areas  were identified  by analyzing  data  on  chemical  contamination
and  biological  effects  (PTI  and  Tetra  Tech  1988).    Areas  received a  high priority
ranking if they exhibited  particularly  high levels of chemical contamination  or  biological
effects, such  as high prevalence  of  liver tumors among bottom-dwelling  fish, or  very  low
abundances of benthic  invertebrate  species.   Known  and  potential  contaminant  sources
were  documented  for   each  priority  problem  area  and for the project area  in general.
This  1989  Action Plan focuses   on controlling  documented  sources  in priority problem
areas.   Generally,  sources  should be controlled prior to conducting sediment remediation
to prevent  or minimize recontamination of cleaned-up areas.

     The  1989  Action  Plan  requires  the coordinated action  of  many  regulatory  and
management  organizations  in  the Interagency  Work  Group  to  address  particular problem
areas   and  specific  sources  of  contamination.   In  addition  to  the  Interagency  Work
Group, business,  industry,  environmental, and  citizen   groups are  represented  in  the
Everett Harbor  Citizens  Advisory  Committee.    The  Citizens  Advisory  Committee  was
consulted to provide direct input into all stages of program development.

     The  1989  Action  Plan  is   being carried out  through  the  existing  regulatory  and
resource management mechanisms  of  federal, state, and  local government  agencies.  Ecology
has assigned  funding for one full-time employee to form  the  nucleus  of a  regional  task
force,  the Everett  Harbor Action  Team,  whose  purpose  is  to identify  and  recommend
controls for contaminant sources.

     The  regulatory  and  management  efforts of the  1989  Action Plan focus  on priority
problem areas  located  in  East Waterway,  along  the  south Port Gardner shoreline  near
Mukilteo, and near industrial and marina areas of the Snohomish  River.
                                           IX

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     The  1989  Action Plan  is a  working document designed  to  be refined as new data
are made available.   The  Everett  Harbor  Interagency  Work  Group will  be  responsible
for updating and  implementing the  1989 Action Plan.   The Interagency  Work  Group  will
continue to  meet  on a  regular   basis  (at  least  quarterly) to  review progress made  on
implementation of the plan, resolve any problems, and refine the plan to reflect new information.

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                                    INTRODUCTION
     In  response  to widespread  concern  over the environmental  health of  Puget Sound,
several   agencies  with   regulatory,   resource   management,   and  research  responsibilities
joined forces in  1985  to initiate the  Puget Sound  Estuary  Program  (PSEP).   A primary
objective of this  program  is  to  minimize  toxic  chemical contamination  of Puget  Sound
to  protect  fish,  shellfish,   wildlife,   and  other  living   resources.     Inner  harbors  and
waterways  of  Puget  Sound,   because  of  their  poor  flushing  characteristics,  are  easily
contaminated  by  toxic   chemicals  released  into  the  sound  or  its  drainage  basin  as  a
result  of  human   activities.   For  example,  localized areas  of  high  contamination  and
associated  biological effects have  been  found  near  discharges from  industrial  facilities,
sewage treatment plants,  and urban storm drains.

     As a primary  element  of  PSEP, the Urban Bay Action Program focuses on identifying
and  reducing contaminant  releases  through  a  series  of coordinated actions by  government
agencies and  private  parties (e.g., industries  and businesses).   Pollution  control  activities
may include  improvement  of  drainage or  treatment  systems  for  stormwater  and sewage;
implementation  and,  where appropriate,  revision  of permit  conditions  for  wastewater
dischargers;  enforcement  of hazardous  materials  regulations; and implementation of  best
management practices or cleanup measures at sites of concern.

     The  1989 Action  Plan for the  Everett  Harbor  Action  Program is described in this
report.   The  corrective  actions developed  for specific  sites  within the  Everett Harbor
project  area  are  organized  according  to problem areas   identified  in  Analysis  of Toxic
Problem Areas (PTI and Tetra  Tech  1988).  For each priority problem area and  associated
contaminant  source, the  plan  specifies  the  status  of discharges  and  corrective actions,
recommended  additional  corrective  actions,  agencies  responsible  for  implementing  those
actions,  and approximate implementation schedules.   The remainder  of  this  introduction
provides  background  information  on  the  project   area,  a  description  of  the  Everett
Harbor  Action Program, and   a summary  of  the   technical approach  used  to  evaluate
priority problem areas and contaminant sources.
OVERVIEW OF EVERETT HARBOR AND ITS TOXIC CONTAMINATION PROBLEMS

      The  Everett  Harbor   project  area,   located  adjacent  to   the   eastern  portion  of
Possession  Sound  in  the north-central  Puget  Sound region, includes  Port  Gardner and
the lower  Snohomish  River estuary (Figure  1).   For the purpose  of this program, Everett
Harbor is  defined as  the  area east  of  a line joining Elliott Point in  Mukilteo  with the
western  point  of  Mission  Beach  at  the entrance of  Tulalip  Bay.  The Snohomish  River
delta  and the estuary east to Interstate 5 are within the project area.

      The  Snohomish  River,  which discharges  into  the  eastern portion  of Port  Gardner,
is  the  major  source  of  fresh  water  to  the  project   area  and  to  north-central  Puget
Sound.   Within the project area, the Snohomish River estuary includes  four main  branches:
Ebey  Slough,  Steamboat Slough,  Union  Slough,  and  the lower Snohomish  River channel.
The  Snohomish River  channel carries  the major portion of  the  river's flow.   During the
dry season, tidal  saltwater  intrusions have been observed as  far upstream as 11 kilometers
from  Preston  Point.    The  Snohomish  River  delta and  associated  sloughs  and  wetlands
together provide  one  of  the  most   biologically  rich  habitats  in  Puget Sound.    Living

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                                                      PROPOSED U.S. NAVY
                                                          HOMEPORT SITE
   PSDDA UNCONFINED
AQUATIC  DISPOSAL SITE
                 U.S. NAVY PREVIOUSLY
             PROPOSED  DEEP CONFINED
                 AOUATC DISPOSAL SITE
                            PREVIOUS  DREDGED
                        MATERIAL  DISPOSAL SITE
           MUKILTEO

           Elliott Point
                                                        Figure 1.  Everett Harbor and lower Snohomish River project area

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resources  of  Everett  Harbor  include  commercially  and  recreationally  harvested  salmon
and  steelhead,   abundant  Dungeness   crab   populations,  several  species  of  perch   and
bottomfish, and  intertidal clams.

     In  the  early  1900s,  a  dike  was built to divert  Snohomish  River flows  southward
along the Everett  shoreline and  to provide  a  channel  for a  freshwater port.   A  second
dike was constructed from the shore  to form the East Waterway.   Historical as well as
recent  maritime  and industrial activities  have  centered  largely around the  East  Waterway
and  along the shoreline northward  to  Preston  Point.    At  present, wastewater outfalls of
major  pulp  and  paper industries  are located in the East Waterway, Steamboat Slough,  and
Port Gardner.   The  depth  of  the Port  Gardner  outfall  is  approximately  100  meters.
The  discharge from the city  of  Everett  wastewater treatment  plant enters the Snohomish
River  approximately 1.6 kilometers downriver  of the  Interstate  5  bridge.   Other  sewage
discharges are located  just offshore of  Mukilteo  (from the  city  of  Mukilteo),  in Ebey
Slough  (from  the  town  of  Marysville)  and  offshore  from  Mission  Beach  (from  the
Tulalip Indian Reservation).   Historical activities  may  also have contributed  contaminants
to the Everett Harbor area.   For example,  in  the  late  1800s  there were several industries
along the Everett-Port  Gardner waterfront, including a  smelter  with an arsenic  concentrating
facility,  a wood  preserving plant,  several lumber mills, a  steel  barge works, and  a  pulp
and paper mill.

     The watershed draining to  the  project  area encompasses  about 280 square kilometers
of primarily  forested  and  agricultural  lands within the  Snohomish River  basin.   Surface
water  runoff  from parts  of  Everett is  collected by  a  combined  sanitary  and  storm
sewer  system  and  treated at  the  Everett aerated   lagoon   wastewater  treatment plant.
Combined sewer overflows (CSOs)  occur at  several  locations during  wet weather conditions
when  the volume  of  stormwater  and municipal  wastewater   (sewage)  exceeds  the  flow
capacity of  the  collection  and treatment system.   There  are  no CSOs  in  Marysville  and
Mukilteo  because   these cities  have  storm  drain  systems  that  are  separated  from  the
sewage collection  systems.   Most  of  the   runoff  from Mukilteo  and  southwest  Everett
enters  directly  into many  small  streams that  discharge to  southern  Port Gardner.   The
northern  portion of the project watershed is largely composed  of forested and agricultural
lands that drain to Quilceda Creek and Allen Creek (east of Interstate 5 on Ebey Slough).

     As  a  result  of  urban  and industrial  influences,  localized areas  of  nearshore   Port
Gardner  and the   lower Snohomish River  have  been  contaminated   by toxic  chemicals.
Investigations by the U.S. Environmental  Protection  Agency  (EPA),  the  National Oceanic
and  Atmospheric Administration, the  Port  of  Everett,  and the  U.S.  Navy  have  revealed
harmful   levels  of  toxic chemicals  in sediments  on  the bottom of  the  bay and  river.
The  discrete  locations  of  pollutant  discharges result  in patches of  toxic  sediments  that
are among some of the most contaminated areas in  Puget Sound.  The  contaminants  include
potential  carcinogens,  such as polychlorinated biphenyls  (PCBs) and polycyclic  aromatic
hydrocarbons  (PAH), and  toxic  resin  acids  and  chlorinated organic  compounds  associated
with wastewater from pulp  and paper manufacturers.

     In   comparison  with  other  contaminated  embayments  of  Puget  Sound,  such as
Elliott Bay  and  Commencement  Bay  where  contaminated areas are more  widespread, the
severely  contaminated  areas of the Everett  Harbor  system are  highly localized,  occurring
mainly  within  the  East  Waterway  and near  Mukilteo.   Liver tumors  were   found  in
approximately 9 percent of English  sole (a  bottom-dwelling  fish)  caught  in  contaminated
areas  of  Everett  Harbor, whereas  these  lesions  are   usually  absent  in  fish  caught  in
relatively uncontaminated  areas  of the sound.   In  addition,  populations  of invertebrate
animals living in the bottom sediments were severely reduced in highly contaminated areas.

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EVERETT HARBOR ACTION PROGRAM

     In  January   1985,   PSEP   member  agencies   initiated  the  Everett  Harbor  Action
Program.    This  program was   built  partly  on the  past  and  continuing  environmental
programs  of the  Washington  Department  of  Ecology  (Ecology), the Port of  Everett,  the
city of Everett, and others.

     Through  a  process  of  interagency   coordination,  local  government   support,  and
public  participation,  the  Everett Harbor Action  Program  has  focused new and  continuing
pollution  control  efforts  on  priority  problem  areas.    The   objectives of  the  Everett
Harbor Action Program include the following:

     •     Identify specific toxic areas of concern  in  sediments of  the  project  area
           based on chemical contamination and associated adverse biological effects

     •     Identify historical and ongoing sources of contamination

     •     Rank toxic problem  areas  and  sources  (to   the  extent  possible)  in terms
           of priority for development of corrective actions

     •     Implement corrective  actions  to  reduce  or   eliminate sources of  ongoing
           pollution  and   restore polluted   areas  to support  natural  resources  and
           beneficial uses.

     The  Everett  Harbor  Action Program  has followed  a  process  in which  corrective
actions  are  developed and  implemented  in  phases  to  take  advantage  of  new  scientific
data  and   emerging  ideas  about  practical  solutions   to  toxic  contamination  problems
(Figure 2).   First,  existing data on  sediment  contamination and  biological  effects  were
analyzed,  and  priority problem  areas  were identified  (Tetra  Tech  1985a).   Second,  data
gaps were filled by further sampling  and  analysis  (PTI and Tetra  Tech 1988; Tetra Tech
1988).   Finally, based on the results  of the  first  steps of the  program, the  1989 Action
Plan  was  developed to  determine  priorities  for   corrective  actions.    The   1989  Action
Plan may  be revised in  the future as  new data become  available  to refine the  definition
of environmental problem areas and contaminant sources.

     Sediment  remedial   actions  and  environmental  monitoring  are  potential   long-term
components  of the   Everett  Harbor  Action  Program.    Examples   of  sediment  remedial
activities   include  capping  contaminated  sediments  with  clean  materials  or  removing
contaminated sediments  by dredging.   Generally,  source  controls  should be  implemented
before  remedial actions   are  taken  on  sediments   to   avoid  recontamination  of an  area
that has been  cleaned up.   Moreover,  sediment remediation is  an  expensive and complex
process that requires considerable site-specific  data and  review of  environmental effects
during  the  planning process.    To  determine the   best course  of action,  regulatory and
resource  management  agencies   must  evaluate  the environmental  benefits   and  risks  of
alternative  sediment  remedial  actions  relative  to  costs.    Monitoring  is  conducted  to
evaluate the effectiveness of source control and sediment remediation (Figure 2).
Implementation of Action Plans

     The  1989 Action  Plan serves as a  blueprint for field investigations,  permit review,
site  cleanup,  and   other   activities   intended  to  control  pollutant  sources.    Activities
specified  in the action plan  are to  be  carried  out  through  the  coordinated efforts  of a

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               INITIAL PROBLEM
                IDENTIFICATION
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SOURCE CONTROL

PERMITTING

INSPECTIONS

ENFORCEMENT

SEDIMENT REMEDIAL
PLANNING
               ENVIRONMENTAL
             MONITORING PROGRAM
               ACTION PROGRAM
                 EVALUATION
Figure 2.  Elements of the Everett Harbor Action Program.

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regional  task  force,  the Everett Harbor Action Team  (EHAT), and  several  agencies  and
other organizations.   Presently,  Ecology  has  funding  for  one  full-time  EHAT member.
Ecology  will  use  its resources primarily  for  carrying  out  source  control  actions.   Such
actions  will  include,  but are  not  limited  to,  the  following:   issuing  permits;  performing
facilities  inspections,  contaminated  site  assessments,  site  investigations,  and  site  cleanup;
enforcing existing regulations; and assisting in the development of educational programs.

      Other important activities  of Ecology and EHAT include the following:

      •     Involvement  in  the  coordination of sediment remedial work (e.g.,  capping
           in   situ   contaminated  sediments   or  dredging  contaminated   sediments
           followed by upland disposal)

      •     Oversight and coordination  of  1989  Action Plan activities  for which  local
           jurisdictions are primarily responsible

      •     Source  identification,  including  performing  field  evaluations and  sampling
           and analysis, and responding to public complaints

      •     Coordination  with  Ecology's  industrial  section on  matters  concerning
           key permits

      •     Organization  and chairing  of quarterly  Interagency  Work Group  meetings
           for Action Plan review  and  update, and  preparation and  distribution  of
           meeting minutes.

      Regulatory authority  for EHAT  stems  primarily from Ecology,   which is responsible
for  issuing  discharge permits  (including  permits  for  storm drains)   and  conducting  site
inspections under  state  water  pollution  control laws  and  regulations,  the  federal  Clean
Water Act,  and  hazardous  substance  control  programs.    Major  regulatory  responsibility
also lies  with the City  of Everett,  which owns and operates  lift stations, pump  stations,
regulators,  and  a  sewage  treatment  plant.    The  City   of  Everett  is  responsible  for
issuing  and  enforcing  permits for  discharges  from industrial  or  commercial facilities  to
the  sanitary  sewer system.   The  City  of Everett also owns  and maintains  storm drain
and sewer collection  systems.   Under  various environmental  regulations,  other  agencies
(e.g., the  Port  of Everett) and  private industries  are responsible  for  pollution  prevention
and abatement  related  to  their  property and  activities, including control of storm drain
discharges.


Past Accomplishments

      EPA  funded  the   development  of  the  Everett  Harbor Action  Program  in  January
1985.   In 1985, EPA presented  draft  reports of the  guidelines for defining toxic  problem
areas based  on measures   of  contamination  and  biological effects,  initial  assessment  of
problem areas based  on available data (Tetra  Tech 1985a), and the  sampling  and analysis
design for further investigations to fill data gaps (Tetra Tech 1985b).

      The  Interagency Work Group  (IAWG) and the Citizens  Advisory Committee  (CAC)
were formed  in 1985 to contribute  to the technical  development of  the  program  and  to
develop  the action  plan.   The IAWG  was composed  of representatives  from  federal, state,
and local government agencies, and the CAC was composed  of  representatives  from business
organizations, industries  in  the study area, and  environmental  groups, as well  as  residents
of  the Everett area who are interested in  the  reduction of  contaminant inputs to the river

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and harbor.  Duties of the Everett Harbor IAWG  and CAC members included:   1) reviewing
program  documents,  agency  policies,  and  proposed  actions;  2)  providing  data  reports
and other  technical information to EPA;  and  3) disseminating  action  program  information
to respective interest groups or constituencies.

     Ecology funded  EHAT in September 1985.   Between September  1985 and September
1987,  EHAT,  in conjunction with  EPA, other  groups at  Ecology, and  local  government
agencies,  performed a variety of source  control actions and initiated  several investigations,
including:

     •     Issuing notices of violation to  two area industries discharging process water
           to Everett's sanitary sewer

     •     Initiating   hazardous  waste   investigations   (with  Snohomish  County)  at
           Paine Field

     •     Conducting source evaluation investigations at two waterfront facilities

     •     Conducting an investigation at the Tulalip landfill

     •     Participating in ongoing investigations  at the Mukilteo  Defense  Fuel Supply
           Depot (Ryan 1987).


TECHNICAL APPROACH

     During  late  1986,  EPA  conducted  field  surveys  to  collect data in  support  of the
Everett Harbor Action Program.  The field  surveys were designed to provide  an assessment
of  environmental  contamination  and effects  (PTI and  Tetra  Tech  1988) and an  initial
evaluation  of  potential  contaminant sources (Tetra  Tech  1988).  This  section  describes
the approach  used to  identify and  rank  problem  areas in terms of priority  for  action
and the approach used to evaluate potential contaminant sources.


Identification and Ranking of Problem Areas

     The five types of environmental indicators (Figure 3) used to identify and rank problem
areas are:

     •     Sediment Chemistry
                 Contaminant concentrations

                 Apparent effects thresholds  (AET), which are  chemical concentrations
                 in  sediments above  which  a  particular adverse  biological  effect  is
                 expected to  be statistically significant  (P<0.05)  relative to appropriate
                 reference conditions

     •     Bioaccumulation

                 Pesticide,  PCB,   and  mercury  concentrations in  muscle  tissue  of
                 English sole

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         Pb
ci
Cl
   C =

      ICHEMISTRYl
                    SEDIMENTS |
              iBIOASSAYSl
 BIOACCUMULATION
LIVER DISEASE
 Figure 3.  Environmental indicators used to define problem areas
          of sediment contamination and biological effects.

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     •     Sediment Bioassays

                Amphipod mortality (10-day bioassay)

                Oyster larvae abnormality

     •     Benthic Infauna Abundances

                Polychaete abundance

                Crustacean abundance

                Pelecypod abundance

                Gastropod abundance

     •     Fish Pathology

                Lesion (e.g., tumor) prevalence in livers of English sole.

The  rationale  for  using  the five  kinds  of environmental  indicators is provided  in  Tetra
Tech  (1985a) and  Tetra  Tech  (1986).   Puget  Sound AET were used  as  sediment quality
values  to  evaluate  chemical data  relative  to  predicted biological  effects.   Because AET
are predictive, they  were  especially  useful  in  interpreting  historical data  on  sediment
contaminant  levels  where no  synoptic biological  data were  available.    Although  many
other   variables  were  evaluated  throughout  the  decision-making  process,   those  shown
above formed the basis for problem identification and priority ranking.

     An  approach  based  on a  preponderance  of  evidence was used to identify and  rank
problem  areas.  Study areas that exhibited high values for  multiple indicators of contamina-
tion  and adverse  effects  received  the highest priority  ranking.    Priority problem areas
and stations  are illustrated in Figure  4.   Corrective  actions  have  not been  identified in
areas  where   problem  sediments  were not  found, although  source control activities  may
be  necessary  to  meet other  regulatory  requirements.    Prioritization of  problem  areas
based  on multiple  indicators  of chemical  contamination   and   biological  effects   will
facilitate effective use of resources for  pollutant  source investigations and  remedial actions.


Identification of Potential Contaminant Sources

     Potential sources  of contamination in the lower Snohomish River and Everett Harbor
include municipal wastewater  treatment plants,  CSOs, surface runoff, contaminated ground-
water,  industrial  discharges, atmospheric  deposition,  and  accidental  spills.   Contaminant
sources in the  Everett Harbor  project area were identified based on the following:   1)
existing  information  about  past   and  present  activities,  and  2)  information  from  site
inspections and discharge  permits.  Information and some  data  were available from Ecology
for facilities  with  permitted  or  known   nonpermitted  discharges,  facilities contributing
to contamination   due to  poor  housekeeping   practices,  and  sites  with  groundwater  or
soils contamination.    Several  major  CSOs  and  storm  drains  were  also  identified  as
contaminant sources.

     To   better  characterize  contaminant  inputs  from  CSOs  and   storm   drains,   EPA
conducted  a  screening-level  survey in  1986 (see  Tetra Tech  1988).   During this  effort,
sediments  were  collected  from  the  downstream   portions of   two CSOs and  one  storm
drain   that discharge  directly  into the  East  Waterway.   In  addition,  four  groundwater
samples  were  collected   from  three  monitoring  wells  at  the   Mukilteo  Defense  Fuel

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                                                     EAST WATERWAY /
                                                      PROBLEM AREA  *

                                                                       I
NEARSHORE PORT GARDNER
       PROBLEM AREA  ^
                    -^•^   —«
                                                                                   NOTE: Problem Slatkin« - Criteria lor defining
                                                                                         problem station! an given In PTI and
                                                                                         Tetra Tech (1988).

                                                                                         Problem Areas - Contain several
                                                                                         problem stations. Unes delineating
                                                                                         problem area* are estimated boundaries
                                                                                         based on available data (Including.
                                                                                         historical data) and are not highly
                                                                                         precise. Station* not exceeding the
                                                                                         criteria may exist within problem areas.
                                                                                                 Reference: PTI and Tetra Tech (1988).
                                                     Figure 4. Problem areas and problem stations in the Everett Harbor
                                                              project area.

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Supply Depot (an area of groundwater contamination). Samples of groundwater from
the Mukilteo  Defense  Fuel Supply  Depot and  samples of sediment  from  the  drains  were
analyzed  for   the  same  contaminants  measured  in  offshore  sediments.    Groundwater,
storm  drains,   and  other  potential  sources  were  evaluated  for  their  potential  contribution
of  contaminants to  priority problem  areas and problem stations identified  in Figure 4.
Tetra Tech (1988) evaluated various  potential sources  based  on the following elements:

      •    Proximity of the potential source to the problem station offshore

      •    Similarity of problem chemicals in sediments of drains and in the receiving
           environment

      •    Similarity  of   the  relative  percent  distribution  of  chemicals   within the
           drain and in   the receiving environment {i.e., percentage  composition for
           a  particular contaminant within  a   group  of related  contaminants  [e.g.,
           low  molecular  weight  PAH (LPAH),  high molecular  weight PAH  (HPAH),
           and metals]}

      •    The spatial distribution of contaminants in offshore sediments

      •    Available information  on past and ongoing practices possibly contributing
           to  observed contamination.

Appendix  A  provides a  summary  of the  source  evaluation for  each problem area and
problem station as  presented  by  Tetra Tech (1988).   The  locations  of   potential  sources
of contaminants are shown in Figures 5 and 6.
                                            11

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SUHFACE RUNOFF  j.bCHAHQE LOCATIONS
CSO
INDUSTRIAL DISCHARGE  EXISTING
.NDUSTRIAL OISCHAHGE - HISTORICAL
TICKSATE
MUNICIPAL WASTE WATER TREATMENT PLANT
EVERETT
WEVERHAEUSER KRAFT
WEYERHAEUSER - WOOD PRODUCTS
ASSOCIATED SAND > GRAVEL
SCOTT/WEVERHAEUSER
WJKLTEO DEFENSE FUEL SUPPLY DEPOT
8URLKGTON NORTHERN RAILROAD
LOCATION OF POTENTIAL CONTAMINANT
SOURCE (INDUSTRIAL)
     BUSE MILL
     BUSE LOG DUMP
     CENTRECON
     MAHPAC
     AMERICAN BOIER WORKS
     FISHERMAN'S BOAT SHOP
     STEUAHT SEAFOOD
     CANYON LUMBER
     TRUCXCARE
     CUSTOM PLATING AND PACIFC PLATING
 1 1 *  KOHKOKU USA
 12*  JOHN FLUKE (SEAWAY BLVD)
 13*  JOHN FLUKE (EVERGREEN WAY)
SEEEASTWATERWAY
     SEGMENT MAP
     DISCHARGES TO EVERETT WWTP
     ;SIGNIFCANT INDUSTRIAL USER
     SUBJECT TO DISCHARGE PERMIT)
                                                                                                               EVERETT
                                                                                                               LANDFLL
                                                                                                              (TIRE RR
                                                                                                                 REKOWAY-SNOHOMISH
                                                                                                                      LANDFLL
                                                Figure 5.   Locations of potential sources of contamination in the
                                                            Everett Harbor  project area.

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         LEGEND
                                                     —I
 (E)

 (S)

(WT)


(SW)

(WG)

 O
SURFACE RUNOFF DISCHARGE

cso

INDUSTRIAL DISCHARGE - EXISTING

INDUSTRIAL DISCHARGE - HISTORICAL

EVERETT

SCOTT PULP AND PAPER

WEYERHAEUSER - THERMAL/
MECHANICAL

SCOTT/WEYERHAEUSER

WESTERN GEAR

STACK

BURLINGTON NORTHERN RAILROAD

LOCATION OF POTENTIAL CONTAMINANT
SOURCE (INDUSTRIAL):

1     FOSS TUG - PAST LOCATION
2    DUNLAP LOG YARD - PAST LOCATION
3    U.S. NAVAL RESERVE C ENTER
4    DUNLAP TOWING

5    JOHNSTON PETROLEUM PRODUCTS
     (MOBILE OIL COMPANY)

6    EVERETT COLD STORAGE
7    FOSS TUG -PRESENT LOCATION
8    DUNLAP LOG YARD -PRESENT LOCATION


DRAIN SAMPLING STATIONS
(TETRATECH 1968)
                                                                    NORTON TERMINAL
                                                                   (PROPOSED U.S. NAVY
                                                                     HOMEPORTSITE)
       +NORTON
 WG003n TERMINAL
I—B-T STORM
      > DRAIN
               SOUTH TERMINAL
              (PORT OF EVERETT)
    SW001
                                                        WEYERHAEUSER
                                                    SULFITE/THERMOMECHANICAL
                                                            (closed)
      Figure 6.   Locations of drain sampling stations, industrial
                  discharge outfalls, CSOs, and storm drains in
                  the East Waterway study area.
                                      13

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                     1989 ACTION PLAN FOR EVERETT HARBOR


     Many  planned or ongoing  actions  to  control contaminant  inputs to  the  project area
are part  of comprehensive  programs  or  planning  activities  of federal,  state, and  local
government  agencies.    The  first part  of this section  describes  these   programs.   The
second  part  of this  section  presents  a  detailed  action  plan for  controlling  contaminant
discharges to priority problem areas.


COMPREHENSIVE PROGRAMS AND PLANS

     The following programs  and  plans are  described  in  terms of  actions  that  can  be
taken  to identify or  control  ongoing  sources  of  contamination  to  the  project  area.
Programs and  plans are organized by major implementing agency  or local  government body.
Programs and  plans  addressing  remediation  of  contaminated  sediment  statewide  are
presently under development by  Ecology.  In addition  to potential future  plans  for sediment
remediation,   contaminated  sediment   removal  may   occur  incidentally,   as  a  result  of
dredging  in navigation  channels  by the  U.S. Army  Corps of Engineers (COE) or dredging
by the U.S. Navy,  the Port of Everett, or other shoreline property owners or tenants.


U.S. Environmental Protection Agency - Superfund

     In  addition  to  the Urban Bay  Action  Program,  EPA  programs  under  the  federal
Comprehensive  Environmental  Response, Compensation,  and Liability Act (Superfund, as
amended) may  result  in activities  to  solve toxic contamination problems in  the  project
area.   Under  Superfund, EPA, Ecology,  responsible parties,  or  potentially responsible parties
investigate  the  extent  of  contamination  in   environmental  media, assess chemical  risks
to  human health  and  the  environment,  and  design  and  implement  cleanup  actions to
reduce or eliminate risks at hazardous waste sites of national priority.

     Currently, there  are  no  National  Priorities List  sites  in  the project  area.  However,
site  discovery  programs under  Superfund  may contribute  to source  identification efforts
of  other agencies.   The  following   Everett  area  sites  are  currently  in the  Superfund
Comprehensive  Environmental  Response   and  Compensation   Law   Information  System
database  for  potential  site discovery,  assessments,  or other actions:    Boeing  Commercial
Airplane  Company, Everett  Landfill,  Pallister  Paint,  Scott  Paper Company,  Simpson  Lee
Company Pulp/Deinking Plant  (closed), Snohomish County Reckoway Landfill, Weyerhaeuser
Sulfite Pulp Mill  (closed), Lake  Stevens  Landfill, Berringer Berry  Farm,  Boeing Company
Tulalip test site, Tulalip landfill, and Mukilteo Defense Fuel Supply Depot.
Proposed U.S. Navy Homeport for a Carrier Battle Group

     The U.S.  Navy  proposes  to  construct and  operate  a carrier  battle group  homeport
at the  Norton  Avenue Terminal  in  Everett.   New  facilities,  including  berthing  space,
are to  be  constructed,  requiring  the  dredging of  sediments  in the  vicinity of  the  East
Waterway.   The Navy  had initially planned  to  dispose  of contaminated  sediments at a
deep  site in  Port  Gardner  (see  Figure 1), capping them  with  uncontaminated  sediments
dredged  from other portions of  the project area.   As  a  result of  an appeal of  the COE
                                           14

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dredging  permit for this  project  by a  group of  environmental organizations,  the plan to
employ confined aquatic disposal for the contaminated sediments was dropped.

     The  in-water portion of  the  homeport construction project has  three  independent
elements, each requiring a separate environmental assessment.   Element 1 will accommodate
the carrier Nimitz  arid six support vessels  at the South  Mole  Wharf and a  new  Carrier
Pier.   A COE  dredging permit for Element 1 will be applied  for during  the  summer of
1989,  with dredging to begin by  the end of  1989.   This  dredging  is expected  to  required
the disposal of approximately  975,000  cubic  yards  of sediments.  These  sediments,  from
the less contaminated  portion  of the  harbor, will nevertheless  be subjected   to  a 3-tier
analysis  (i.e.,   review   of existing  data,  bulk  chemical  analysis,  and acute bioassays)
required  by the  Puget Sound  Dredged  Disposal  Analysis (PSDDA)  program,  as well as
additional  analyses (i.e., bulk  chemical  analyses for  polar  organics,  and sublethal bioassays)
to  determine  the  appropriate  disposal  option.    If  these  sediments  are found  to  be
suitable  for  unconfined open-water  disposal, then they may be  disposed of at  the  PSDDA
site in Port Gardner (see Figure  1), at  the previously  proposed confined  aquatic disposal
site in Port  Gardner (see  Figure 1), or  at an approved upland site, subject to  negotiations
between  the  state  and the  Navy.   If  these sediments   are  found to  be unsuitable for
unconfined open-water disposal, then  they will be disposed of at an approved upland site
(with  an option to store  them  for up  to 5  years  on the Navy property).   Completion of
Element 1  is scheduled  for the summer of  1992.

      Elements  2  and  3  of  the homeport project will  involve construction of additional
berthing  facilities  and  additional  dredging,  including dredging  of  contaminated  sediments
from   the  East  Waterway.   One option under consideration for disposal  of  these  sediments
is to  construct an earthen berm  in the  inner portion  of the  East Waterway, dispose of
the contaminated  sediments  inside  this  berm, and cover  these  sediments  with  a cap of
clean  fill  material.  Further details of Elements  2  and  3, including the selected sediment
disposal option, will be specified at a later date.


Washington Department of Ecology

      In addition   to the  Urban  Bay Action  Program, Ecology  has a number  of  ongoing
programs  and  planning  activities  related  to toxic contamination  in  the  Everett Harbor
project area.  Programs that are most  directly related to  the  control of  toxic  contaminants
are described below.
      National  Pollutant  Discharge  Elimination  System (NPDES)--Permits  are generally
 issued  on  a  site-by-site basis and  can  include  more than  one discharge  or source  of
 pollutants.    Permits  for  municipal  wastewater  treatment  plants  cover  sewage   system
 discharges throughout  the plant's service area.  Industrial permits may include requirements
 for  storm  drain  control  (for  surface runoff)  and  wastewater discharge  control.   NPDES
 permits  may  specify  effluent limits (concentration  or total loading)  for toxic contaminants
 and may  include  provisions for instituting best  management  practices to reduce  nonpoint
 contaminant inputs.

      There are three NPDES-permitted facilities in  the  project  area:   Mukilteo  Defense
 Fuel Supply  Depot,  Weyerhaeuser  Kraft Mill,  and  Scott Pulp  and Paper  Mills  (Tetra  Tech
 1988).   New NPDES  regulations  require  property  owners  and tenants in certain  land use
 categories  to  submit  data  regarding surface  water  runoff.    Ecology  is  reviewing  this
 information to assess the need for issuing stormwater permits  for selected facilities.
                                            15

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     Resource  Conservation  and  Recovery  Act (RCRA)--The  joint EPA/Ecology RCRA
program   governs  the   generation,  handling,  and  disposal  of  hazardous  wastes.    Spill
prevention  and   containment   measures,   material   handling  requirements,   groundwater
monitoring, and site cleanup can be required as part of a RCRA permit.


     Sediment Standards  Development—Ecology has been  a lead agency or key  participant
in several efforts  to  develop   tools for  evaluating  and  managing  contaminated  sediment
(e.g.,  Commencement  Bay Superfund project,  PSDDA, Urban  Bay  Action Program,  and
Puget Sound Water Quality Management Plan).   Ecology  is  currently developing  sediment
quality   standards,  effluent   particulate  controls,   standards  for  confined  disposal   of
dredged  material,  and  remedial action  (i.e., cleanup)  guidelines.   In  addition, guidelines
for unconfined  disposal of  dredged material have been  developed  under PSDDA  in an
interagency effort led by the COE.
Snohomish Conservation District

     Snohomish  Conservation  District  is  responsible for  providing  planning assistance  to
farmers  in  Snohomish County.   The  district's main source of  funding for this  task  is  a
4-year grant from  Ecology.   The grant specifies  that the district  work within the boundaries
of  the  Snohomish  River  watershed.    The scope  of work for  this effort  consists of  the
following four major elements:

     •     Inventory existing commercial livestock operations

     •     Provide  conservation planning  assistance  on  a  voluntary basis to livestock
           operations,  with  an  emphasis  on reducing agricultural  nonpoint  source
           pollution

     •     Provide  technical assistance to implement conservation plans for livestock
           operations

     •     Provide  information-sharing  and educational services  on improving  water
           quality to commercial and small farm operators.

     The  Everett  Harbor  Action  Plan  identifies  Quilceda  Creek  and  Allen  Creek  as
potential  sources  of  agricultural  nonpoint contamination.   These  streams  are  within  the
boundaries of the  Snohomish  River  watershed and  are part  of the Conservation  District's
planning  responsibility.     The  Conservation  District  has  completed  an  inventory  of
livestock  operations,  and  has  identified 14  dairies  within the  Quilceda Creek and  Allen
Creek  drainages.   Conservation  plans  have  been  completed  for 2  of the  14  dairies  and
the  remaining  dairy operators  have  been  encouraged  to   participate   in   conservation
planning  activities.    In  addition,  the  Conservation  District assisted  in the installation of
winter  manure  storage facilities at five  dairies in the  Quilceda Creek and  Allen Creek
drainages.

     The  Conservation   District  publishes   the   Snohomish   Conservation   News,  which
encourages  farmers to  get  involved in  improving  water quality  by  adopting  agricultural
best management  practices  and  participating  in  ongoing  watershed planning  activities.
All  commercial  and  noncommercial  livestock  operators  in  Snohomish  County receive
Snohomish Conservation News.
                                            16

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     The Snohomish River  watershed project is  funded  by Ecology  through 1990.  After
1990, local funding support will be essential for continuation of the program.


Snohomish Health District

     The Snohomish Health  District is  responsible for the  protection of  public  health in
Snohomish County,  including  all  incorporated cities and  towns.   As  a  regulatory agency,
the  Health  District's  mandated  responsibilities   include  enforcing  solid  waste  disposal
regulations  and  monitoring   existing solid  waste  facilities,  permitting  upland  disposal
sites  for  dredged  material,   and  permitting  private  onsite  sewage  treatment  systems.
Other  important activities and responsibilities  of  the  Snohomish  Health  District  include
the following:

     •     Participation  on  the Snohomish County Solid  Waste  Committee,  the City
           of Everett's  Solid  Waste  Committee  and Wastewater Disposal Committee,
           and the Snohomish County Watershed Advisory Committee

     •     A  notification  program  to   educate   the   public  about  possible   health
           risks  associated  with   the   harvesting  of  shellfish  and  bottomfish  in
           Everett Harbor

     •     Operation of a drinking water  certification laboratory

     •     Public   assistance   concerning   household   hazardous   waste   and  small
           quantity waste generators.


City of Everett

     The  City of  Everett  has  three   programs  to   reduce  contaminant  inputs  to   the
Everett Harbor project  area:   the CSO control  plan,  the industrial pretreatment program,
and ongoing activities at the sewage treatment facility.


     Combined Sewer  Overflow  Control  Plan--The  City  of Everett  developed  a CSO
control  plan  in  1987  (CWC-HDR  and  Ott Water  Engineers  1987)  in  response  to   the
requirements  of Ecology.   The  city's  10-year  implementation  plan  includes  installing a
new interceptor  line  from  Port  Gardner  to the  Snohomish River, constructing a  south-
end interceptor  line,  implementing  a  program  to identify  and  control  inflows  to   the
south-end  system,  constructing  a siphon  and  oxidation pond  in  the Snohomish  River
area,   achieving  stormwater/sewer   separation   at  three  Snohomish  River   CSOs,  and
constructing  a Snohomish  River  interceptor  (CWC-HDR and Ott  Water Engineers  1987).
CSOs  are  currently  monitored by  the   city to  determine  their  frequency  and  intensity
for  the  purpose  of establishing  CSO  control  priorities.    A  plan approved  by Ecology
provides that control efforts  for  CSOs  discharging to  the  sound  (i.e., E006,  E007, E008,
E009, E011,  E012, and  E013)  will not begin until at least 1993.  The city  will concentrate
CSO control efforts  on  the  Snohomish  River where CSO  volumes  are  at  least  ten times
greater (Thomas, R., 14 November 1988, personal communication).


     Industrial  Pretreatment Program--The City of Everett has developed  and implemented
an  industrial  pretreatment  program,  which  includes   industrial  waste  surveys,  discharge
limitations,  a  monitoring enforcement  system,   and a  public participation  program.   As
                                            17

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of  September  1988,  the  city  had  identified  industries  needing  permits  and  had issued
permits to two facilities (Thomas, R., 24  August 1988,  personal communication).   As  of
November 1988,  the  city  had drafted  permits  for  Kohkoku, Inc.; Centrecon, Inc.; Cathcart
Landfill;  Stewart Seafoods;  Boeing,  Inc.;  Pacific Plating;  Custom  Pacific  Plating;  and
Truckcare, Inc. (Thomas,  R.,  14  November 1988,  personal communication).   These permits
are currently being reviewed by Ecology.


     Municipal Wastewater Treatment Plant--The City of Everett has  conducted studies
of  1)  an  alternative  outfall  site and addition  of a  flow-paced  chlorination  system  for
effluent  disinfection  and  2)  ambient  lead concentrations  in  the Snohomish  River.   The
city has  constructed  recirculation  channels for the  existing  lagoons.   Sediment  will  be
removed  from  the  aeration  cells by  mid-1989.   The  city  will  design and  construct  a
mechanical treatment  plant by 1991 (Thomas, R., 24  August 1988, personal communication).


Puget Sound Water Quality Authority

     Puget  Sound  Water  Quality  Authority  (PSWQA)  is a state   agency mandated  to
develop a comprehensive plan for water quality protection in Puget Sound for implementation
by existing state and local governments.   The  1989 Puget Sound Water Quality Management
Plan,  released in  November  1988, builds on  elements  and  goals  set  out  in the  1987
Puget  Sound  Plan (PSWQA  1988).  The  1989 plan delineates criteria, guidelines, sources
of  funding,  management  strategies, budgets,  and schedules  for  10  programs  relating  to
nonpoint  source  pollution  control, shellfish protection, municipal and  industrial  discharges,
contaminated sediments  and dredging,  stormwater and combined  sewer overflows, laboratory
support,  wetlands  protection,  oil  spill  prevention  and  response  planning,   household
hazardous waste, and  legal  and personnel support.

     In addition, the 1989 plan identifies three new initiatives  (i.e.,  for monitoring, research,
and education and public  involvement)  and a 14-item  unfinished agenda.   Implementation
of  the plan has  resulted  in  the  adoption  of  new state  regulations  and the  formation  of
state  and local  programs  that  are  important  to  the  Everett  Harbor Action  Program
(e.g.,  watershed  planning).   Of  most  importance  to the  Everett  Harbor  Action Program
are  the  requirements   for  Ecology  to  develop  and  adopt  sediment  quality  standards,
enhance  the  control of contaminant  discharges from  permitted  facilities,  and  develop  a
stormwater control program.


U.S. Army Corps of Engineers - Puget  Sound Dredged Disposal  Analysis

     The  COE conducts  regular  maintenance  dredging  in the Snohomish River  navigation
channel and settling  basins every 2 years.  In  addition, the  COE  is  one  of the principal
agencies in Puget Sound regulating the dredging and disposal of dredged  material (including
contaminated sediment). The  COE is the lead  agency for PSDDA.  Other major  participants
in the  program are the Washington Department of Natural Resources, EPA,  and Ecology.

     The  primary objectives  of  PSDDA are  to 1) identify acceptable  sites for the  open-
water  unconfined disposal of  dredged  material,   2)  define  dredged  material  evaluation
procedures  for  sediments  that   are being considered  for disposal   at  the PSDDA  sites,
and 3) formulate management plans for disposal  sites.    Phase  I  of PSDDA, completed  in
                                            18

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December  1988,  focuses on  central Puget  Sound (including  Everett  Harbor).   The  PSDDA
unconfined  aquatic  disposal  site for  Port Gardner has  been established  (see  Figure  1).
As  of February  1989, no  permits  have been issued.   Phase II  deals  with the remainder
of Puget Sound and is expected to be completed by Fall 1989.
Port of Everett

     Planned   expansion  of  port  facilities  may  incidentally  result  in  the  remediation
(i.e., removal)  of contaminated sediment.   By  1989,  the  Port  of Everett plans to demolish
the  shoreline   area  now  occupied  by  a  dock  on  the  old Weyerhaeuser  property  (South
Terminal).  This  project may create an opportunity for the  nearshore or upland-confined
disposal  of an  estimated  3,800  cubic meters  of  contaminated sediment  from the  East
Waterway problem area.
Paine Field Cleanup Committee


     The  Paine  Field Cleanup  Committee was  formed in  1987  to  assess hazardous waste-
related  problems and  oversee  their solution.   This  interagency  group  is  composed  of
representatives from Ecology,  Snohomish  County Airport, Olympus Terrace Sewer District,
Snohomish Health  District,  Snohomish County Safety Department, and the  COE.    This
group  supervised the  sampling and analysis  of  approximately  120  underground  storage
tanks  in   1987   and 1988  and  is  coordinating various  other  investigations  and  cleanup
efforts, including sampling and disposal of drums,  installation and sampling of groundwater
monitoring wells,   sampling  and  removal  of  underground  storage   tanks,  mapping  the
storm drain and sanitary sewer system, and managing landfill operations.
SITE-SPECIFIC ACTION PLAN

      Table 1 presents  the 1989 Action  Plan  for  EH AT and associated agencies.   Problem
areas and problem stations correspond  to  those  defined in PTI and  Tetra Tech (1988).
Figure  4  above  illustrates  the  locations  of  problem areas and problem  stations in  the
Everett  Harbor  project  area.    (Problem  Station  SD-03  does  not  appear  in   Table   1
because   there  are  no   known  potential  sources  associated   with  the  area  sampled.)
Sources  listed in  Table  1  are  those  identified  in  Evaluation  of  Potential Contaminant
Sources  (Tetra Tech 1988)  and those identified  by members of the  IAWG.  The actions
and  personnel  specified  in  Table  1 reflect  information  and   commitments  from  IAWG
members.    The  implementation  dates  document actual and  projected  start/finish  dates
for each action.
                                           19

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                                                TABLE 1. SITE-SPECIFIC ACTION PLAN FOR EVERETT HARBOR PRIORITY PROBLEM AREAS
           Problem Areas & Stations
                                                     Potential
                                                      Source
                                                                                                                 Action
                                                                    Responsible
                                                                       Entity
                                                                                                                                       Implementation
                                                                                                                                           Date
K>
O
East Waterway Problem Area              Norton Terminal storm drain


                                        Scott Pulp and Paper


                                        Anaconda Aluminum Dome

                                        Everett Cold Storage

                                        Mobil Oil Co.

                                        Dunlap Towing

                                        Everett Terminal Company

                                        U.S. Naval Reserve

                                        CSO E011, E008, E009, E006, and E0073


Nearshore Port Gardner Problem Area     Defense Fuel Supply Depot


                                        Mukilteo wastewater treatment plant


                                        Powdermill Gulch
                                                                                          Develop  an  approach  for  addressing  infiltration  of
                                                                                          contaminants.

                                                                                          Perform a Class II inspection and modify permit to include
                                                                                          toxic chemical control if necessary.

                                                                                          Inspect site and  issue permit if needed.

                                                                                          Inspect site and  issue permit if needed.

                                                                                          Inspect site and  issue permit if needed.

                                                                                          Inspect site and  issue permit if needed.

                                                                                          Inspect site and  issue permit if needed.

                                                                                          Issue NPDES permits for storm drains.

                                                                                          To be eliminated
Work with  EPA personnel to institute remedial activities
(e.g., product recovery).  Remedial investigation in progress.

Construct pump station and transfer effluent to Olympus
Terrace sewage treatment plant

Implement drainage basin plan, including sampling.

Conduct  a  reconnaissance  survey  for  surface drainage
sources.
                                                                                          Conduct an investigation of past disposal practices and land
                                                                                          use.
                                       Japanese Gulch


                                                                               Conduct sampling and analysis to characterize discharge.


                                       Snohomish County Airport - Paine Field     Investigate potential sources.
           Problem Station OG-01
CSO EOOl/Edgewater Creek"


Scott-Weyerhaeuser deepwater diffuser
                                                                                          Continue activities to characterize,  clean up, and prevent
                                                                                          contamination.

                                                                                          Install interceptor sewer to eliminate CSO.
                                                                               Conduct a Class II inspection and modify permit to include
                                                                               toxic chemical control if necessary.
                                                                                                          Ecology/EHAT


                                                                                                             Ecology


                                                                                                             Ecology

                                                                                                             Ecology

                                                                                                             Ecology

                                                                                                             Ecology

                                                                                                             Ecology

                                                                                                               EPA

                                                                                                          City  of Everett


                                                                                                           Ecology/EPA


                                                                                                         City of Mukilteo


                                                                                                          City  of Everett

                                                                                                         Ecology/EHAT
                                                                Ecology Hazardous
                                                                  Waste Division

                                                                  Ecology/Water
                                                                Quality Investigation

                                                                     Ecology
                                                                                                                                               Paine Field Cleanup
                                                                                                                                                   Committee

                                                                                                                                                 City of Everett
                                                                     Ecology
      1989


      1989


      1989

      1989

      1989

      1989

      1989

    Ongoing

  Starting date
     -1993

      1989


      1990


      1989

      1989


      1990


      1989


 Investigation
Completed 7/88

    Ongoing


Completed 1988


      1989

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TABLE 1.  (Continued)
Potential
Problem Areas & Stations Source
Problem Station SR-05 Weyerhaeuser Kraft Mill WK002,
WK004, WK005
Everett wastewater treatment plant




Log storage yards
Problem Station ES-03 Tulalip landfill

Quilceda Creek

Marysville wastewater treatment plant
Boeing test facility
Problem Station SR-07 Marina area

CSOEOl^
CSOEOIS^
Surface runoff
Action
Perform a Class II inspection and modify permit to include
toxic chemical control if necessary.
Conduct a study for alternative outfall site and flow-paced
chlorination system.
Conduct a study on ambient lead levels in the Snohomish
River, including low-flow (summer) conditions.
Implement pretreatment program.
Construct recirculation channels for lagoons and dredge
sediment from aeration cells.
Design and construct mechanical plant.
Inspect site and issue permit if necessary.
Develop financing mechanisms for placing capping material
over landfill.
Sample leachate and receiving water for pathogens.
Continue conservation planning and technical assistance
efforts at dairies, and continue public education/public
involvement effort
Perform a regional detention facility study.
Add eight influent aerators and three grinders.
Investigate possible hazardous waste leachate to Quilceda
Creek.
Investigate potential sources, including pretreatment
permitted facilities, boat repair facilities, storm drains, and
boat basin.
Issue permits
To be eliminated
To be eliminated
Monitor
Responsible
Entity
Ecology
City of Everett/Ecology
City of Everett
City of Everett
City of Everett
City of Everett
Ecology
Tulalip Tribes
Ecology/EHAT, EPA
Snohomish Conservation
District/Tulalip Tribes
Snohomish Conservation
District
City of Marysville
Boeing/Ecology
Ecology
Ecology
City of Everett
City of Everett
Ecology/COE
Implementation
Date
1989
Completed
Completed
Ongoing
6/89
1988-1991
1989
Ongoing
Completed 1988
Ongoing
1990
1990
1989
Completed 1987
1989
1992
1992
1989
" CSO E006-Approximately 100 meters southeast of Pier 1
  CSO E007-Approximatery 80 meters southeast of Pier 1
  CSO E008-Approximately 100 meters southeast of Pier 3 (at the foot of Hewitt Avenue)
  CSO E009-Approximately 300 meters north of Pier 3 (at the foot of 25th Street).
  CSO EOll-Approximatery 300 meters north of CSO E009 (at the foot of 23rd Street).
fc CSO EOOl-Adjacent to Eedgewater Creek.
c CSO E012-At the foot of 16th Street in the marina.
d CSO E013-AI the foot of 14th Street in the marina.

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                                    REFERENCES
CWC-HDR  and  Ott  Water  Engineers.    1987.   Combined  sewer overflow  control  plan.
Prepared for the City of Everett.  CWC-HDR, Inc., Edmonds, WA.

PSWQA.    1988.   1989  Puget  Sound Water  Quality Management Plan.   Draft  Report.
Puget Sound Water Quality Authority, Seattle, WA.

PTI  and Tetra Tech.   1988.   Everett  Harbor Action Program:   analysis of toxic problem
areas.   Final  Report.   Prepared  for  U.S. Environmental  Protection Agency  Region  10,
Office of Puget Sound.  PTI Environmental Services and Tetra Tech, Inc.,  Bellevue,  WA.

Ryan,  C.   1987.  The Urban Bay  Toxics  Control Program:   action team accomplishments.
Washington Department of Ecology, Olympia, WA.  43 pp.

Tetra Tech.   1985a.   Everett  Harbor Toxics Action  Program:   initial data summaries and
problem  identification.    Final   Report.    Prepared  for   U.S.  Environmental   Protection
Agency, Region  10, Office of Puget Sound.  Tetra Tech, Inc., Bellevue, WA.

Tetra  Tech.   1985b.   Sampling  and analysis design for  development  of  Everett  Harbor
Action  Plan.   Prepared for U.S.  Environmental  Protection  Agency Region 10,  Office of
Puget Sound.  Tetra Tech, Inc., Bellevue, WA.

Tetra  Tech.   1986.   Everett  Harbor  Toxics  Action Program:   review  of existing action
plans.   Final Report.   Prepared  for  the U.S.  Environmental  Protection  Agency  Region
10, Office of Puget Sound.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.   1988.   Everett  Harbor Action Program:   evaluation of  potential  contaminant
sources.   Final  Report.  Prepared  for U.S. Environmental Protection Agency, Region  10,
Office of Puget  Sound.  Tetra Tech,  Inc., Bellevue, WA.

Thomas, R.   24 August  1988.   Personal  Communication  (telephone conversation  with Mr.
P. Booth, PTI  Environmental Services, Bellevue, WA).  City of Everett, Everett, WA.

Thomas, R.    14 November  1988.   Personal  Communication (letter  to  Mr.  J.  Williams,
Washington Department of Ecology). City of Everett, Everett, WA.
                                           22

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        APPENDIX A



SOURCE EVALUATION SUMMARY

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                          SOURCE EVALUATION SUMMARY
     This appendix presents  a summary  of  the source  evaluations for  each  high priority
problem  area and  problem station [Figure 4;  see Tetra Tech (1988) for additional informa-
tion].
EAST WATERWAY PROBLEM AREA

     Many  compounds related to  the  pulp industry  (e.g., resin acids, chlorinated  phenols,
and  chlorinated  guaiacols)  were  found  at  elevated  concentrations  in  the  sediments  of
the East  Waterway.   The  most likely  sources  of these contaminants  are historical  and
current discharges  from  pulp and  paper  mills.   Scott  Paper Company and an  inactive
Weyerhaeuser: thermomechanical   plant  located  near  the  East  Waterway  problem  area
have  historically  discharged  effluent in  or near the problem  area  through nine identified
outfalls.

     The Scott  Paper Company  has operated  a plant  at  its  East Waterway  location  since
1930, and  currently discharges effluent through a  deepwater  diffuser (SW001), a nearshore
diffuser (S003), and the secondary treatment plant outfall (S008).

     Weyerhauser operated a sulfite-based paper and pulp mill from  1936  until 1975.  Before
1951,  discharges  included  untreated  wastewater  from  washing,  bleaching,  and drying
processes  (WT002 and WT003);  stormwater runoff  and wastewater  from limestone  cleaning
operations   (WT004);   and stormwater   runoff   from other  areas  of  the  plant  (WT006).
After  1951,  most  sulfite  waste  liquor  was   discharged  through   the  plant's  deepwater
diffuser  (SW001).   In  1975,  the  plant was converted  to  the thermomechanical  process,
and  outfalls WT001 and  WT003 were  sealed and abandoned.   After 1975, outfalls WT004
and  WT006 were  used  only  for  stormwater  discharge.   Weyerhaeuser closed  operations
at its East Waterway plant in  1980.

     Six  CSOs  and  10 storm drains  also  discharge to  the  East  Waterway  problem  area.
Only the Norton Terminal storm drain and CSOs E011  and E007 were sampled during  the
1986  source  investigation.   Analytical  results indicate  a lack  of similarity  in  problem
chemicals  (presence  of  chemicals   and  their   relative   distributions) between  the  Norton
Terminal storm drain and offshore  sediments,  suggesting that the  storm drain was not  a
significant contributor to  organic chemical contamination in the East Waterway.   However,
the  storm  drain  may have contributed  to metals  contamination  offshore  that  had  not
reached problem levels at the time of sampling (Tetra Tech 1988).

      Based on  the  large  number  and relative  distributions  of problem  chemicals  common
to both CSO E011  and stations in  East Waterway,  it is likely that CSO E011 has contributed
to  chemical contamination  of sediments in East  Waterway  (especially  by 4-methylphenol
and  PAH).    However,   the  data  indicate  that  there  were  probably other  significant
sources in the vicinity of CSO E011, especially for compounds related  to the pulp industry.

      Chemical analyses of  sediment sampled from CSO E007 indicate  that  the CSO  may
be a source of HPAH and  metals to  the  East  Waterway, but is not likely a major source
of 4-methylphenol.   The  sediment sample from CSO E007 was not analyzed for  pulp mill
compounds.
                                          A-l

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NEARSHORE PORT GARDNER PROBLEM AREA

     Polar organic compounds  (e.g.,  4-methylphenol, benzole acid, and  phenol) were  the
major  contaminants in the  sediments  of  this problem  area.   Some stations demonstrated
relatively  high concentrations  of  PAH  and  PCBs.   Potential  sources  of contamination in
the vicinity  of this  problem area  include the Mukilteo  Defense Fuel  Supply Depot,  the
Mukilteo   municipal   wastewater   treatment   plant,  and  three  surface  water  discharge
points  (i.e.,  Japanese  Gulch,  Edgewater Creek,  and  Powder  Mill  Gulch).    Although
ground water  samples taken  from  wells  at the Defense Fuel  Supply Depot in  1986 were
visibly  contaminated with  oily  substances,  chemical analyses  yielded  only  a few target
compounds (i.e., a few metals and PAH) at relatively low concentrations (Tetra Tech 1988).

     No  data  are available for characterizing  surface  waters  discharging  to  the  offshore
Port Gardner problem  area.  A number of  potential sources  of contamination are present
in  the  drainages  of  the  three  creeks  mentioned  above  (e.g.,  abandoned  landfills   and
dumps, and training areas for firefighting exercises in the Snohomish County  Airport/Paine
Field area).    An  Ecology  field  investigation of  the  Paine Field  area  was  underway at
the time of this writing.


PROBLEM STATION OG-01

     Station  OG-01  was  located  near  the Scott  Paper  Company diffuser  (SW001).  This
area was  characterized  by  contamination from  4-methylphenol,  PAH,  resin acids, and  a
cymene isomer.   These  contaminants have  varying  degrees of  association with  the  pulp
industry.   Outfall SW001  is  currently  used  to  discharge  effluent from  the  Scott Paper
Company  primary clarifiers.  Prior to  1980, the outfall was  also  used by  Weyerhaeuser
for  the  discharge  of  a variety   of  effluents  including   untreated sulfite  waste  liquor.
These  discharges  may have been  the  source  of resin acids  in  the  vicinity  of Station
OG-01.
PROBLEM STATION SD-03

      Station SD-03  was located  in  the Snohomish River  delta offshore from a  historical
Western  Gear  outfall (WG002).   Western  Gear specialized in  the  manufacture  of heavy
equipment and  machinery  for  the  oil drilling industry,  and discharged noncontact cooling
water prior  to  1988.   Sediments  in  this  area  exhibited  contamination by  benzoic  acid,
benzyl alcohol,  DDT, and 4-methylphenol.   No potential  sources for  any of the  problem
chemicals  have been identified.  The  presence  of  DDT  in sediments  from this  area may
be due to historical agricultural uses in the Snohomish River drainage basin.


PROBLEM STATION SR-05

      Station SR-05  was  located  in  the Snohomish  River offshore of the  Weyerhaeuser
Kraft Mill.   Sediment  in  this area was contaminated with benzoic acid,  4-methylphenol,
and  resin acids.   Discharges from  one  or more  Weyerhaeuser outfalls  are  likely sources
of  resin  acids  and  possibly 4-methylphenol.   Historical  outfall  WP001  was  upriver  of
Station  SR-05  and  discharged filtration  backwash.   Outfall  WK.002  is  slightly  downriver
of  Station  SR-05 and  discharges  noncontact cooling water.   Outfall WK.005  is slightly
downriver and  across  the river  from  Station SR-05  and  discharges  surface  runoff  from
Smith Island.   Outfall WK.001  is  on the northwestern side of Smith Island and discharges
                                           A-2

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effluent  from aerated  treatment  lagoons.    This  outfall  was  probably  not  a  source  of
contaminants  to  the area because  of its  distance  from Station SR-05.    Potential  sources
of benzoic acid have not been identified.
PROBLEM STATION ES-03

     Station  ES-03  was  located  in  Ebey  Slough  southeast  of  the  mouth  of Quilceda
Creek.  Sediments in this area exhibited contamination from benzoic acid, 4-methylphenol,
and  phenol.   A  potential source of the  benzoic  acid  and phenol  contamination  is leachate
from the Tulalip  landfill, which has  been known  to contain these contaminants.    Wood
waste  and   treating  facilities  are  present  at  various   locations  throughout  the   lower
Snohomish  River  and its  sloughs,  and  were  possible contributors  to  the  4-methylphenol
contamination  observed at this  station.   Weyerhaeuser Outfall WK.001  is another  potential
source of 4-methylphenol in the vicinity of Station ES-03.


PROBLEM STATION SR-07

     Station SR-07 was  located near  the  Everett Marina in the Snohomish  River,  and  was
designated  a problem station because  of benthic  effects.    Sediments  at  Station  SR-07
are  composed of  96 percent fine-grained material.   Fine-grained  sediments may  be  the
cause  of the  observed  benthic  effects.   Sediments  contained  elevated  concentrations of
tributyltin and  sulfides.   Other  chemicals were  not  significantly elevated.   Tributyltin  is
used in  marine  paints  as  a biocide  and  may  have originated  from  boat  painting  and
refinishing  activities in  the marina   area.    Potential   sources  of  sulfides  in  this   area
have not been identified.
PROBLEM STATION SD-01

      Station  SD-01   was  located  in  the  Snohomish  River  delta,  and  was  designated  a
problem station  because of benthic  effects.   Sediments in the area  contained  12 percent
gravel,  less  than 5   percent  fine-grained material,  and low concentrations  of organic
carbon and sulfide.    No  significantly elevated concentrations  of problem chemicals  were
observed at  this  station.    Benthic  effects observed in  this  area  may  be  the  result of
natural  physical  stresses such  as those caused  by  swift  currents in  the area rather than
chemical contamination (PTI and Tetra Tech 1988).
                                           A-3

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